Public companies have four business days to disclose a material cyber incident — and the SEC's new enforcement unit has already settled $8M+ in actions. We make sure the regulator finds nothing to file, and the plaintiff's bar finds nothing to subpoena.
// CURRENT THREAT LANDSCAPE
Financial cyber events stopped being IT problems years ago. Today they're board-level risk events with cascading exposure across federal regulators, state attorneys general, customers, and the press — often within the same business week.
// SEC DISCLOSURE CLOCK
4 days
SEC Item 1.05 gives public companies four business days to disclose a material cyber incident. The new CETU unit has already settled $8M+ in enforcement.
SEC Item 1.05 · CETU Enforcement 2026
// FTC SAFEGUARDS RULE
$51,744
The amended Safeguards Rule covers nearly every non-bank financial firm. Breaches affecting 500+ customers must be reported to the FTC within 30 days — and become public record.
FTC 16 CFR § 314 · 2025 Adjustment
// PERSONAL OFFICER LIABILITY
5 years
GLBA imposes personal liability on officers and directors: up to $10K per violation, and up to 5 years imprisonment for willful violations. Caremark now treats cyber oversight as a board duty.
15 U.S.C. § 6823 · Delaware Chancery
// COMPLIANCE LANDSCAPE
Financial firms answer to a stacked enforcement environment — SEC, FTC, banking regulators, and state attorneys general, each able to penalize you independently. The SEC doesn't need a security failure to act, only a disclosure that doesn't hold up. The firms that drew enforcement in 2025 had the weakest paperwork, not the weakest security. We make sure yours holds.
// SERVICES
Our entire methodology is mapped to the regulatory environment financial firms operate in — not bolted on as a vertical afterthought.
// 01
When the SEC, FTC, or state regulator opens an examination, your SEC Item 1.05 documentation is the difference between a closing letter and a multi-million-dollar consent order.
SEC · GLBA · SOC 2 · PCI DSS · NYDFS
// 02
The 24/7 operational layer behind the documentation — vCISO leadership and continuous defense calibrated to the high-value-asset attack patterns financial firms actually face.
vCISO · SOC · ZERO TRUST · VENDOR RISK
// 03
The SEC's four-day clock starts the moment a material incident is determined. Prepared firms finish that clock. The unprepared get crushed by it — in public, on Form 8-K.
IR · BC/DR · TABLETOP · 4-DAY CLOCK
// WHO WE SERVE
// 01
Community banks, regional institutions, and credit unions operating under FFIEC examination standards, GLBA obligations, and OCC, FDIC, FRB, or NCUA supervision.
// 02
Registered investment advisors, wealth advisors, and family offices subject to SEC Reg S-P, the Custody Rule, and fiduciary-duty standards — all with client trust as the core asset.
// 03
Accounting firms, tax preparers, and bookkeeping practices subject to the FTC Safeguards Rule, IRS Publication 4557 / WISP requirements, and AICPA professional standards.
// 04
Public companies subject to SEC Item 1.05 + Item 106 disclosure, pre-IPO firms preparing for S-1 cyber disclosures, and private companies in regulated finance partnerships.
// CLIENT BRIEF
The thorough guidance of WatchUr6 has enabled us to develop an effective and manageable security plan. Now, we have secure, streamlined processes and feel confident in our compliance. If you're considering their services, don't hesitate. Cybersecurity is vital to business success. You won't regret it!
Rebecca Casarez, CPA
President & Managing Partner · ProAdvisor CPA
// OPERATIONAL HERITAGE
From protecting national-security assets
to protecting the capital, client data, and fiduciary trust your firm runs on.
// EXECUTIVE LIABILITY
The Caremark doctrine now reaches cybersecurity: Delaware courts are letting shareholders sue directors personally for failing to oversee cyber risk — stacked on GLBA's personal officer penalties, including up to 5 years imprisonment for willful violations. The defense is documented reasonable care. We build that evidentiary record, so the CEO, CFO, and board are covered when something goes wrong.
// THE NEXT MOVE
// FREQUENTLY ASKED
Under Form 8-K Item 1.05, public companies must disclose material cybersecurity incidents within four business days of determining that the incident is material. The four-day clock starts at the materiality determination — not at incident detection — but the SEC has explicitly stated that deliberate delay of the materiality determination triggers additional violations.
The rule has remained operative through 2026 despite banking-industry petitions for its rescission. Annual cybersecurity risk-management and governance disclosures under Regulation S-K Item 106 apply alongside it. The SEC's new Cyber and Emerging Technologies Unit (CETU), launched in February 2025, has already settled over $8 million in cyber-disclosure enforcement actions.
Almost certainly yes. The FTC interprets "financial institution" broadly under the Gramm-Leach-Bliley Act. CPA firms, tax preparers, mortgage brokers, RIAs, financial advisors, and any other entity "significantly engaged in financial activities" — including those handling client tax returns, financial planning, or credit applications — fall within the rule's scope.
The amended Safeguards Rule (effective June 2023) requires nine specific elements including a designated Qualified Individual, written information security program, risk assessment, MFA, encryption, annual penetration testing, and a breach-reporting program. Civil penalties run up to $51,744 per violation per day, and breaches affecting 500+ customers must be reported to the FTC within 30 days — a notification that becomes public record.
Officers and directors of financial institutions face escalating personal-liability exposure on multiple fronts.
GLBA imposes personal civil penalties of up to $10,000 per violation on individual officers and directors, plus criminal penalties of up to 5 years imprisonment for willful violations. Institutional fines can reach $100,000 per violation.
The Delaware Caremark doctrine — extended post-Marchand v. Barnhill — allows shareholder derivative suits to proceed against directors who failed to implement systems to detect and respond to mission-critical risks. Cyber oversight is now squarely a Caremark obligation for financial-sector boards.
Documenting reasonable care — written policies, risk assessments, board-level cybersecurity reporting, vendor risk management, and incident-response playbooks — is the single most important defense.
SOC 2 is an AICPA-governed private-sector audit framework that produces a Type I or Type II attestation report covering the Trust Services Criteria (Security, Availability, Processing Integrity, Confidentiality, Privacy). It's increasingly demanded by enterprise customers, partners, and counterparties as a precondition to doing business — especially for technology vendors, fintechs, and B2B service providers.
PCI DSS is the Payment Card Industry Data Security Standard governed by the major card brands. It's required of any entity that processes, stores, or transmits payment card data. Non-compliance triggers brand fines, acquirer chargebacks, and potential loss of payment-processing privileges.
Many financial firms need both. SOC 2 satisfies institutional partners and customers; PCI DSS satisfies payment processors and the card brands. We map both frameworks back to the same underlying control infrastructure so you build it once.
The four-business-day disclosure window starts the moment materiality is determined. The SEC's new Cyber and Emerging Technologies Unit (CETU) is the dedicated enforcement arm focused on disclosure violations and emerging-technology fraud — operational since February 2025.
Between December 2023 and early 2025, 54 public companies filed 80 Form 8-K disclosures under Item 1.05 and related provisions. SEC enforcement focus has shifted, post-SolarWinds dismissal, toward fraudulent disclosure — affirmative misrepresentation, deliberate concealment, and materiality determinations designed to delay reporting — rather than judgment calls on nuanced characterization.
Practically: the SEC can issue comment letters or open an investigation within days of a public disclosure or media report. Pre-built disclosure templates, materiality decision frameworks, and board-level escalation paths are how prepared firms get through it without an enforcement action.
WatchUr6 serves the full financial-services market:
Community banks & credit unions — FFIEC examination prep, GLBA programs, vendor risk management.
Wealth advisors & RIAs — SEC Reg S-P compliance, Custody Rule controls, fiduciary-grade documentation.
CPA firms & tax practices — FTC Safeguards Rule, IRS Publication 4557 WISPs, AICPA-aligned programs.
Public & pre-IPO companies — Item 1.05 + Item 106 readiness, S-1 cyber disclosures, board reporting infrastructure.
The regulatory framework applies regardless of size, and so does our methodology.
// NEXT MOVE
30 minutes with a veteran-led financial security team. We'll walk your SEC/GLBA/FTC posture, your most likely enforcement exposure, and what your board needs to be able to document. No sales theater — whether you hire us or not.